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Compliance Voluntary Disclosure Government Investigations

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Bradley Arant Boult Cummings LLP

Criminal Division’s new voluntary self-disclosure program still uncertain and risky

On April 15, 2024, the Department of Justice released its “Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals.” Similar in many ways to programs introduced earlier this year by the U.S. Attorney’s...more

Venable LLP

Recent DOJ Memo on Corporate Criminal Enforcement Highlights Critical Considerations for Employers

Venable LLP on

On September 15, 2022, the Department of Justice (DOJ) released a long-anticipated memo announcing changes to its corporate criminal enforcement policies (Memo). The Memo contains helpful guidance for employers, outlining...more

Jackson Walker

DOJ Officials Announce New Priorities to Combat Corporate Crime with Additional Details Provided at Government Enforcement...

Jackson Walker on

On Thursday, September 15, 2022, Deputy Attorney General Lisa A. Monaco outlined new steps the Department of Justice will be taking in its ongoing efforts to police corporate crime. The next day, Assistant Attorney General...more

BCLP

DOJ Issues Policy for Export Control and Sanctions Enforcement (IRB No. 580)

BCLP on

On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses.  The updated policy now offers voluntary...more

Bass, Berry & Sims PLC

Mixed Messages: DOJ Releases New FCA Cooperation Guidelines, while Study Questions Whether Cooperation Actually Garners Credit

Bass, Berry & Sims PLC on

The U.S. Department of Justice (DOJ) routinely encourages the subjects of False Claims Act (FCA) enforcement actions to make voluntary disclosures and fully cooperate with the government on the premise that cooperation leads...more

Jones Day

DOJ Issues Guidance on Cooperation in FCA Cases

Jones Day on

The U.S. Department of Justice seeks to use the potential for a reduced penalty amount and damages to encourage self-disclosure of misconduct and cooperation during FCA investigations. On May 7, 2019, the U.S. Department...more

Mintz - Health Care Viewpoints

DOJ Issues Guidance on Cooperation Credit in FCA Settlements

The U.S. Department of Justice (DOJ) issued policy guidance on May 6, 2019, about providing credit in False Claims Act (FCA) settlements to corporations for “disclosure, cooperation, and remediation." DOJ has never previously...more

Bradley Arant Boult Cummings LLP

DOJ Provides Guidelines for Reducing False Claims Act Settlements through Cooperation - Government Enforcement Update

This week, the Department of Justice (DOJ) formalized and expanded its guidance for how defendants can earn cooperation credit in False Claims Act (FCA) cases and thereby reduce settlement amounts. New section 4-4.112 of the...more

Thomas Fox - Compliance Evangelist

Soft Skills in Remediation: Part V – Post Resolution

I conclude my five-part series on the soft skills a Chief Compliance Officer (CCO) needs to employ when working through the remediation component of a potential Foreign Corrupt Practices Act (FCPA) compliance violation. I...more

The Volkov Law Group

Fokker: No Judicial Oversight of Deferred Prosecution Agreements

The Volkov Law Group on

The D.C. Circuit dealt a blow last week to judicial attempts to exercise supervision over Justice Department negotiated Deferred Prosecution Agreements. In United States v. Fokker, the Court answered the question in a...more

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